3.3 Worker safety and health compliance approach
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Statutory Documents - IMO Publications and Documents - Resolutions - Marine Environment Protection Committee - Resolution MEPC.210(63) – 2012 Guidelines for Safe and Environmentally Sound Ship Recycling – (Adopted on 2 March 2012) - Annex – 2012 Guidelines for Safe and Environmentally Sound Ship Recycling - 3 Ship Recycling Facility Plan (SRFP) - 3.3 Worker safety and health compliance approach

3.3 Worker safety and health compliance approach

3.3.1 Worker health and safety

 In this section of the SRFP, the Ship Recycling Facility should provide a comprehensive description of the Facility's plans and procedures for protecting worker health and safety and should reflect applicable requirements of the Convention (particularly regulations 19 and 21 to 23) and national legislation. The Ship Recycling Facility should also take into account, as appropriate, guidelines developed by international organizations. A reference list of these guidelines is provided in appendix 4. The SRFP should identify and demonstrate the Ship Recycling Facility's knowledge and understanding of applicable worker safety and occupational health processes, procedures, laws, regulations and guidance. Further, the SRFP should demonstrate that the safety and health programme supports the activities necessary for environmental compliance and for recycling and disposal at the Ship Recycling Facility.

3.3.2 Key safety and health personnel

 The SRFP should identify one or more key personnel who possess the level of training and experience necessary to effectively ensure that safe conditions are maintained during operations at the Ship Recycling Facility, including one or more Competent persons for the performance of specific work. Depending upon the size of the Ship Recycling Facility and the number of workers, the SRFP could include a hierarchy of safety and health management staff, including an overall manager, supervisory staff and general workers.

3.3.3 Job hazard assessment

 The SRFP should include the procedures to be implemented to conduct a job-hazard assessment to determine the proper approach to maximizing worker safety. Responsibility for job hazard assessments should be assigned to a Competent person for the specific hazards of each job. It is recommended that the assessments should be conducted by a team of personnel including the Competent person, a representative of management and workers with the appropriate level of expertise.

3.3.4 Prevention of adverse effects to human health

  Regulation 19 of the Convention specifies that the Ship Recycling Facility shall establish and utilize procedures to prevent explosions by ensuring that Safe-for-hot-work and Safe-for-entry conditions are established and maintained throughout the ship recycling process; to prevent other accidents that cause or have the potential to cause damage to human health; and to prevent spills of cargo residues and other materials which may cause harm to human health and/or the environment. Since these are among the more critical aspects for the safe operation of Ship Recycling Facilities, it is important that the SRFP clearly demonstrates that it has procedures in place to prevent workplace accidents and injuries. The guidelines below outline the key considerations that should be included in the SRFP.

3.3.4.1 Safe-for-entry procedures

 Throughout the entire recycling process, the Ship Recycling Facility should ensure that, prior to entry and during work, enclosed spaces and other areas where the atmosphere is dangerous are monitored to ensure that they remain Safe-for-entry and safe for continued activity. The Ship Recycling Facility should ensure that shipboard spaces are not entered until a Safe-for-entry certificate has been issued by a Competent person. A Competent person should visually inspect and test each space on the ship to determine the areas which are safe for entry before issuing a certificate and before recycling activities are commenced.

 Safe-for-entry certification, inspection and testing should be conducted in all spaces that have the potential to pose harm to human health as a result of the space's oxygen content, flammability or atmospheric toxicity, with particular attention paid to enclosed spaces and to spaces and adjacent spaces where hot work has been or will be performed during the course of the daily recycling work.

 Designation as "Safe-for-entry" is not sufficient for hot work, as additional criteria should be met to address safety issues related to hot work.

3.3.4.1.1 Safe-for-entry criteria

 For entry purposes, steady readings of all the following should be obtained:

  • .1 the oxygen content of the atmosphere is 21 per cent by volume, measured using an oxygen content meter (Note: National requirements may determine a safe atmosphere range);

  • .2 where the preliminary assessment has determined that there is potential for flammable gases or vapours, the concentration of those gases or vapours is not higher than 1 per cent of their lower flammable limit (LFL), measured using a suitably sensitive combustible gas indicator; and

  • .3 the concentration of any toxic vapours and gases is not higher than 50 per cent of their occupational exposure limit (OEL)footnote.

If these conditions cannot be met, the space should be ventilated further and retested after a suitable interval.

3.3.4.1.2 Competent person for Safe-for-entry determination

  Regulation 1 of the Convention defines "Competent person". The Competent Authority should define the appropriate criteria for designation of a Competent person. However, the Competent person(s) for Safe-for-entry and/or Safe-for-hot-work determination should be able to determine oxygen content, concentration of flammable vapours and gases and the presence of toxic, corrosive, irritant or fumigated atmospheres and residues. The Competent person should possess sufficient knowledge and practical experience to make an informed assessment based on the structure, location and designation of spaces where work is done. The Competent person should possess the ability to inspect, test and evaluate spaces to determine the need for further testing. The Competent person should also monitor the maintenance of appropriate conditions in spaces.

3.3.4.1.3 Safe-for-entry inspection and testing procedures

 Designation as "Safe-for-entry" is not sufficient for hot work, as additional criteria must be met to address safety issues related to hot work. Testing should be carried out by a Competent person using appropriate and properly certified and calibrated equipment, including, but not limited to, an oxygen content meter, combustible gas indicator, toxicity meter and gas or vapour detection equipment.

3.3.4.1.4 Oxygen

 The Ship Recycling Facility should ensure that spaces are tested by a Competent person to determine the atmosphere's oxygen content prior to initial entry into the space by workers, and also that the space is periodically monitored and recorded for as long as it is occupied. Spaces that warrant particular consideration include the following:

  • spaces that have been sealed;
  • spaces and adjacent spaces that contain or have recently contained combustible or flammable liquids or gases;
  • spaces and adjacent spaces that contain or have recently contained liquids, gases or solids that are toxic, corrosive, or irritant;
  • spaces and adjacent spaces that have been fumigated; and
  • spaces containing materials or residues of materials that create an oxygen-deficient atmosphere.

A worker should only enter a space where the oxygen content, by volume, has the value noted in 3.3.4.1.1. In such a case, the space should be labelled "Safe-for-entry". If an oxygen-deficient or oxygen-enriched atmosphere is found, ventilation should be provided at volumes and flow rates sufficient to ensure that the oxygen content is maintained at the value noted in 3.3.4.1.1. The label may be reattached when the oxygen content returns to the value noted in 3.3.4.1.1, and after it has been tested and inspected by the Competent person.

3.3.4.1.5 Flammable atmospheres

 The Ship Recycling Facility should ensure that spaces and adjacent spaces that contain or have contained combustible or flammable liquids or gases are visually inspected and tested by the Competent person prior to entry by workers, and that they are periodically monitored and the results recorded throughout the time that the spaces are occupied.

 If the concentration of flammable vapours or gases in the space to be entered is equal to or greater than 1 per cent of the lower flammable limit, then no one should enter the space and the label "Safe-for-entry" should be removed. Ventilation should be provided at volumes and flow rates sufficient to ensure that the concentration of flammable vapours is maintained below 1 per cent of the lower flammable limit. The label may be reattached when the concentration of flammable vapours falls below 1 per cent of the lower flammable limit and after it has been tested and inspected by the Competent person.

3.3.4.1.6 Toxic, corrosive, irritant or fumigated atmospheres and residues

 The Ship Recycling Facility should ensure that spaces or adjacent spaces that contain or have contained liquids, gases or solids that are toxic, corrosive or irritant are visually inspected and tested by a Competent person prior to initial entry by workers.

 If a space contains an air concentration of a material which exceeds 50 per cent of their OEL, then no one should enter the space and it should not be labelled "Safe-for-entry". Ventilation should be provided at volumes and flow rates sufficient to ensure that air concentrations are maintained below 50 per cent of their OEL. The label may be reattached when the concentration of contaminants is maintained below 50 per cent of their OEL and after it has been tested and inspected by the Competent person.

3.3.4.1.7 Safe-for-entry determination by a Competent person

 A Competent person should visually inspect and test each space certified as "Safe-for-entry" as often as necessary to ensure that atmospheric conditions within that space are maintained within the conditions established by the certificate. However, at a minimum, the space should be inspected and tested at least once in an eight-hour shift period. The results of these tests should be recorded on the Safe-for-entry certificate.

 When a change occurs that could alter conditions within a tested enclosed space or other dangerous atmosphere, work in the affected space or area should be stopped. Work may not be resumed until the affected space or area is visually inspected and retested by the Competent person and found to comply with the certification. It is recommended that the space should be ventilated and the atmospheric conditions returned to the acceptable limits after a space has been found to exceed limits.

 If the Competent person has initially determined that a space is safe for an employee to enter and they subsequently find that the conditions within the tested space fail to meet the requirements, work should be stopped until the conditions in the tested space are corrected to comply with the certification requirements. If it is safe to do so, the Competent person may be asked to investigate the reason for the space's non-compliance and to ensure that the remedial action to be taken will prevent a reoccurrence.

3.3.4.1.8 Safe-for-entry certificate, warning signs and labels

 Any determination of a space as "Safe-for-entry" should be accompanied by a certificate which, at a minimum, should clearly indicate the following information:

  • name and title of the Competent person performing the test(s) and inspection(s);
  • signature of the above person;
  • name of vessel and location;
  • the areas of the ship that are Safe-for-entry;
  • date and time of the inspection;
  • location of inspected spaces;
  • tests performed;
  • type of equipment used in testing;
  • test results;
  • period of retesting of the spaces;
  • results of periodic retesting undertaken;
  • conditions when the Competent person should be recalled or conditions that void the certificate;
  • safety designation(s) ("Safe-for-entry", "Not Safe-for-entry");
  • validity period and expiration date of the certificate, recommended to be a maximum of 24 hours, with periodic retesting intervals not exceeding eight hours;
  • type of ventilation; and
  • any additional relevant information or instructions.

 Safe-for-entry certificates should be posted at every access point between ashore and the ship. A record of inspection of atmospheric tests should be appended to the certificate.

 The certificate and/or the spaces themselves should be clearly marked and presented in a manner that can be seen and understood by all workers in the working language of the yard and, if possible, with pictorial representations.

 If an entire work area has been tested and labelled with the proper signage (for example, as being "Safe-for-entry") at all points of access to the work area, an individual tank or other space located within the work area need not be labelled separately.

 The certificate, updates and any other records should be kept on file for a period of at least three months from the completion date of the specific job for which they were generated.

 If a space at any time ceases to meet the Safe-for-entry criteria, the label "Safe-for-entry" should be removed.

3.3.4.1.9 Safe-for-entry operational measures

 In addition to ensuring certification as "Safe-for-entry", the following operational measures should also be observed:

  • no person may open or enter an enclosed space unless authorized by the Competent person of the Ship Recycling Facility and unless the appropriate safety procedures have been followed;
  • a permit for entry has been issued for those intended to enter the space by the same individual(s) who is/are responsible for maintaining the certificate on behalf of the Ship Recycling Facility, confirming that all certification processes and operational measures for safe entry have been completed and are in effect;
  • the space is properly illuminated;
  • there is appropriate access and egress to the space and the working area in the enclosed space is suitable for the work that is being considered, specifically for heavy, large or complex lifting operations;
  • a suitable system of communication between all parties for use during entry is agreed upon, tested and used;
  • the space is adequately isolated from gases, liquids or other identified hazardous substances that could inadvertently be released into the space in which work is being undertaken;
  • a fully-trained supervisor, who may be in charge of one or more work teams, has oversight of the area and frequently monitors the conditions to which the workers are exposed;
  • the style of ventilation equipment is such that no ignition sources are introduced into a hazardous space;
  • the ventilation provided for the space is adequate for the work to be undertaken and for any diurnal variation in environmental conditions that may be experienced in hot or humid regions;
  • the ventilation system is designed to prevent the persistence of gas pockets within tanks/spaces – owing either to the complex structure of the tank/space or to the fact that the gas pockets are heavier than air vapours in the tank – which may be achieved by suction/evacuation style ventilation rather than blower ventilation;
  • in the event of ventilation system failure, some means of alert is provided so that any persons in the space can leave immediately;
  • appropriate rescue and fire control plans are in place;
  • appropriate personal protective equipment (PPE), protective clothing and safety equipment (including harnesses and lifelines) are provided to the workers, and used during entry to and work in the designated spaces; and
  • adequate and functioning rescue and resuscitation equipment has been provided and is positioned ready for use at the entrance of the space.

If the fire alarm is activated, the space should be evacuated until the all-clear for re-entry is given by the Competent person.

3.3.4.2 Safe-for-hot-work procedures

 The Ship Recycling Facility should ensure that no hot work commences on a ship unless the area is deemed "Safe-for-hot-work".

 Safe-for-hot-work certification, inspection and testing apply to all of the following:

  • enclosed spaces and all other spaces enclosed by bulkheads and decks (including cargo holds, tanks, quarters, and machinery and boiler spaces) that potentially contain dangerous atmospheres;

  • within, on, or immediately adjacent to spaces that contain or have contained combustible or flammable liquids or gases;

  • within, on, or immediately adjacent to fuel tanks that contain or have last contained fuel;

  • on pipelines, heating coils, pump fittings or other accessories connected to spaces that contain or have last contained fuel; and

  • bilges, cargo holds, engine room spaces and boiler spaces not containing dangerous atmospheres.

 The Ship Recycling Facility should ensure that no hot work commences in any of these spaces until Safe-for-hot-work certification has been issued by a Competent person; these inspections and tests should be entered on the record of inspection and testing and posted in a conspicuous place on board. A Competent person should visually inspect and test each space on the ship to determine the areas which are deemed "Safe-for-hot-work" before a certificate is issued and before recycling activities commence.

3.3.4.2.1 Safe-for-hot-work criteria

 A space that is "Safe-for-hot-work" is one that meets all the Safe-for-entry criteria and also the following criteria:

  • any residues or materials in the space are not capable of producing an oxygen-enriched or oxygen-deficient environment, and are not capable of generating flammable or explosive vapours;
  • all adjacent spaces have been cleaned, rendered inert or sufficiently treated to prevent the risk of explosion, the release of noxious or toxic fumes or gases and the spread of fire; and
  • work in adjacent spaces is not affected by the hot work, such as tank entry, lifting operations or deconstruction by hand.

3.3.4.2.2 Competent person for Safe-for-hot-work determination

 A Competent person for matters related to Safe-for-hot-work determination should meet the criteria identified in 3.3.4.1 and possess the additional knowledge and skills required to handle hot work activities.

3.3.4.2.3 Safe-for-hot-work inspection, testing and determination

 Each space should be certified by a Competent person as "Safe-for-hot-work" as often as necessary to ensure that conditions within that space are maintained as established by the certificate. The frequency with which a space should be monitored to determine whether conditions are being maintained is a function of the following, but should in any event not exceed an eight-hour shift period:

  • temperature: any changes in temperature in the space could result in a change in its atmospheric conditions, and hotter days can cause residues to produce more vapours, resulting in a greater risk of flammable or explosive conditions;
  • work in the space: activity in the space can change its atmospheric conditions; gas leaks from a hose or torch or manual tank cleaning by scraping or using hand-held high-pressure spray devices can stir up residues, which can result in a greater risk of flammable or explosive conditions;
  • period of elapsed time: if a sufficient period of time (not to exceed 24 hours) has elapsed since Safe-for-hot-work certificate was issued, the condition of the space should be retested prior to entry and commencement of work;
  • unattended spaces: a tank or space that has been certified as "Safe-for-hot-work" then subsequently left unattended for a sufficient period of time should be retested prior to entry and commencement of work;
  • work break: tanks or spaces should be checked for equipment left behind when workers take a break or leave at the end of the shift, and the condition of the tank or space should be retested prior to entry and resumption of work; and
  • ballasting or trimming: changing the position of the ballast or moving or trimming the ship in any way can produce a change in the atmosphere of the spaces; the condition of the spaces should be retested prior to entry and resumption of work.

3.3.4.2.4 Safe-for-hot-work certificate, warning signs and labels

 Any determination of a space as "Safe-for-hot-work" should be accompanied by a certificate which, at a minimum, should include the information identified in section 3.3.4.1.8 ("Safe-for-entry certificate, warning signs and labels"). Warning signs and labels should be posted in the manner described in section 3.3.4.1.8 for Safe-for-entry determination, clearly indicating that the space is "Safe-for-hot-work".

3.3.4.2.5 Safe-for-hot-work operational measures

 In addition to the measures identified in section 3.3.4.1.9 ("Safe-for-entry operational measures"), the following should also be applied in order to achieve certification as "Safe-for-hot-work":

  • each area where hot work is to be performed should be carefully prepared and isolated before hot work commences;
  • all trash, debris, oil residues or other materials that could generate flammable or explosive vapours should be removed from the space prior to commencing hot work. The space and adjacent spaces should be kept free of any trash, debris, oil residues or other materials that could result in a risk of flammable or explosive conditions;
  • drums and similar small containers which have contained flammable substances should, before they are cut, be either filled with water or thoroughly cleaned of such substances;
  • deck tanks should be appropriately cleaned, gas freed and certified as Safe-for-entry and tested for hot work as described in the general sections (see sections 3.3.4.1 and 3.3.4.2). A suitable supply of fresh air should be maintained, given that oxygen from the atmosphere may be removed in the combustion process. The tanks should be isolated and tested in accordance with the guidance given in these guidelines. Particular attention should be paid to access and egress and to the unique challenges presented by these spaces regarding tank rescue in an emergency situation;
  • fixed cargo or fuel tanks should be cleaned and ventilated before any work commences and after having been passed as "Safe-for-entry" and "Safe-for-hot-work". Cleaning should be sufficient to remove any hazardous liquids, light solids and clinkage to allow the tank to be gas freed. Complex structures may require additional preparation before being certified as "Safe-for-hot-work". The need for localized manual cleaning should be considered. Ventilation should allow an adequate flow of air to all parts of the space to prevent a build-up of gases either from the hot work or from the tank coatings;
  • ventilation should be provided at volumes and flow rates sufficient to ensure that the concentration of flammable vapours is maintained below 1 per cent of the lower flammable limit;
  • general mechanical ventilation should be of sufficient capacity and so arranged as to produce sufficient air changes to maintain safe levels of welding fumes and smoke; and
  • the Ship Recycling Facility's fire safety procedures should be followed.

3.3.4.3 Welding, cutting, grinding and heating

 The SRFP should include procedures for ventilation, personnel monitoring for heavy-metals exposure, protection of personnel, training, respiratory protection, torch cutting, permits and inspections (including hot-work certification). The SRFP should include procedures for transporting, moving, securing, storing and using hoses and torches.

3.3.4.4 Drums, containers and pressure vessels

 The SRFP should include procedures for handling, transporting and storing pressure vessels containing flammable gases, such as acetylene (C2H2), propane gas (C3H8) or oxygen (O2) for welding, heating and cutting works, in order to avoid any human injuries, caused by external forces, shock or heat to such vessels.

 Procedures for removing pressure vessels containing carbon dioxide (CO2), nitrogen (N2) and other ozone-depleting substances used in fire-fighting and refrigeration systems should also be included.

 Procedures for transporting and storing drums and containers containing hazardous liquids, using appropriate PPEs, should also be described in the SRFP.

3.3.4.5 Prevention of falling from heights and accidents caused by falling objects

 The SRFP should include procedures for using personal flotation devices, guarding deck openings, deck edges and platforms, utilizing personal fall arrest systems and guard rails and ensuring safe access to ships to prevent slip-and-fall accidents and the dropping and scattering of objects.

3.3.4.6 Gear and equipment for rigging and materials handling

 The SRFP should include procedures for testing and inspecting ropes, chains, slings, hooks, chain-falls and hoisting and hauling equipment. It should further include a description of operations using cranes, machines, mobile equipment and aerial and man-lift systems and a list of qualifications required for the operators.

3.3.4.7 Housekeeping and illumination

 The SRFP should include procedures for work areas, such as aisles, passageways and temporary deck openings.

3.3.4.8 Maintenance and decontamination of tools and equipment

 The SRFP should include procedures for inspection and maintenance of equipment, regulatory requirements for third-party inspections and decontamination procedures. These activities and the result of the inspections should be recorded.

 The Ship Recycling Facility should ensure that the quantity and the deployment of tools and equipment are suitable for the corresponding recycling activities, especially when a number of ships are to be recycled at the same time.

3.3.4.9 Health and sanitation

 The SRFP should include a description of washing facilities, showers, eating and recreation areas, toilet facilities and changing rooms. It is recommended that appropriate changing rooms and sanitary and washing facilities should be provided by the Ship Recycling Facility to control exposure and avoid the spread of Hazardous Materials. Sanitary and washing facilities should be conveniently accessible and situated so that they are not at risk of contamination from the workplace. Separate and appropriate changing rooms and sanitary and washing facilities should be provided for exclusive use by workers handling asbestos. It is also recommended that the Ship Recycling Facility should designate separate and uncontaminated areas for workers to use for eating, drinking and other breaks.

3.3.4.10 Personal protective equipment

 The SRFP should include information on procedures and equipment used for the protection of employees from various risks associated with ship recycling.

 Respiratory protection and hearing conservation programmes should be developed for all employees who could be exposed to excessive levels. The SRFP should describe how the programmes are in compliance with national regulations. In the absence of domestic law, the Ship Recycling Facility should utilize best industry practices to provide effective respiratory protection and hearing conservation programmes.

3.3.4.11 Worker exposure and medical monitoring

 The SRFP should include procedures to be used for monitoring exposure and for medical surveillance.

3.3.5 Emergency preparedness and response plan (EPRP)

  Regulations 18.5 and 21 of the Convention specify that Ship Recycling Facilities shall establish and maintain an emergency preparedness and response plan (EPRP). While the EPRP could be incorporated into the SRFP, it is highly recommended that the EPRP should be a separate, self-contained document. By having it as a self-contained document, the information contained within is more readily available and easily accessible, and the Ship Recycling Facility may want to distribute copies to several locations at the site. It is also helpful to have a summary page at the front of the document for quick access, showing 24-hour contact information (including telephone numbers) for the appropriate contact personnel (such as management personnel and emergency response personnel).

 The SRFP should identify the locations where the EPRP will be readily available, and should contain a brief summary of the EPRP, so that the appropriate entities (such as those that are authorizing facilities) or other relevant stakeholders can easily confirm that it exists. The EPRP should take into consideration a wide variety of potential scenarios, including, but not limited to, human injuries, environmental accidents, extreme acts of nature and the activities of the surrounding community (such as an emergency at a nearby chemical processing plant).

 The EPRP should, at a minimum, include the Facility's response to:

  • fire or explosion or ingress of water on the ship being recycled or awaiting recycling, within the perimeter of the Facility, or in an adjacent facility;
  • accidents to workers within the Facility;
  • spillages of Hazardous Materials; and
  • probable acts of nature in the area concerned, such as earthquakes or flooding.

 The location, physical and environmental characteristics of the Ship Recycling Facility and the size and nature of activities associated with each ship recycling operation should be taken into consideration during preparation of the EPRP. The EPRP should do the following:

  • ensure that the necessary equipment – including fire hydrants, extinguishers, first-aid facilities, clean-up equipment, breathing apparatus, alarms and signals and details of training arrangements that are commensurate with the possible emergency situations likely to occur at the Ship Recycling Facility – and emergency procedures are in place, and that drills are being held on a regular basis;
  • provide for the information and internal communication and coordination necessary to protect all people in the event of an emergency at the Ship Recycling Facility;
  • provide information to and ensure communication with the relevant Competent Authority(ies) or organization recognized by it, the surrounding community and the emergency response services;
  • provide for first-aid and medical assistance, fire-fighting, evacuation of all people from the Ship Recycling Facility (including emergency escape route and muster station) and pollution prevention measures such as the response to spills of Hazardous Materials (including the safe handling of spilled or emitted materials and the procedure for cleaning contaminated areas);
  • provide visible indications of location of first aid stations, fire control stations and evacuation routes;
  • further ensure the provision of relevant information and training to all workers at the Ship Recycling Facility, at all levels and according to their competence, including regular exercises in emergency prevention, preparedness and response procedures; and
  • include procedures for recording of an emergency incident and investigation and corrective actions following an emergency incident.

3.3.6 Fire and explosion prevention, detection and response

 The Ship Recycling Facility should have systems in place for preventing fires and explosions and for fire-fighting, by controlling any outbreak of fire quickly and efficiently and by quickly and safely evacuating all personnel at the Facility. The SRFP should provide for the following:

  • sufficient and secure storage areas for flammable liquids, solids, and gases;
  • procedures for the prohibition of smoking through "no smoking" notices;
  • precautions to be implemented in spaces where flammable gases, vapours or dust can cause danger (no naked light or flame or hot work should be permitted unless the space has been tested and deemed safe by a Competent person); and
  • procedures for the proper storage of combustible materials, greasy or oily wastes and scrap wood or plastics.

 The SRFP should also include procedures for regular inspections of spaces where there are risks of fire and explosion. This includes the vicinity of heating appliances, electrical installations, conductors, stores of flammable and combustible materials and areas where operations involving hot welding, cutting, grinding and heating are conducted. The appropriate precautions to reduce the risk of fire and explosions from welding, flame cutting and other hot work should be identified.

 The SRFP should include procedures for the provision and selection of fire-extinguishing equipment according to the provisions of applicable international and national laws and regulations, and should record the results of the initial hazard identification and risk assessment of the Ship Recycling Facility operations. Equipment deployment should take account of the following: any restrictions to access or egress to spaces inside the ship; the quantity and characteristics of hazardous, flammable and explosive substances handled in ship recycling operations; site transport and storage facilities; and first-stage fire-fighting demands (such as hand-held or trolley-mounted portable fire extinguishers).

 The SRFP should identify the locations of the fire-extinguishing equipment, ensuring that they are readily available, easily visible and in accessible areas. Adequate water supply should be provided in places where the danger of fire exists (in accordance with national laws and regulations).

 The SRFP should include procedures for the provision, proper operation, maintenance and regular inspection of all fire-extinguishing equipment by a Competent person. Access to fire-extinguishing equipment, such as hydrants, portable extinguishers, and connections for hoses, should be kept clear at all times.

 The SRFP should describe procedures for providing suitable training, instruction and information to all supervisors and workers (including details of the frequency of such training) about the hazards of fires, appropriate precautions to be taken and use of fire-extinguishing equipment, so that adequately trained personnel are readily available during all working periods. Records of training and drills/exercises should be maintained, including such information as type of training/drill, role of person trained, equipment used, duration, location, date and time.

 The SRFP should include procedures for the installation of sufficient, suitable and effective warning signals (such as sight and sound signals) in case of fire. There should be an effective evacuation plan so that all personnel are evacuated speedily and safely. The SRFP should include procedures for posting notices in conspicuous places indicating, if applicable, the nearest fire alarm, the telephone number and address of the nearest emergency services and the nearest first-aid station.


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